Information regarding the Legal Systems of Countries to Which Personal Dataof Natural Persons Is Transferred in the Process of Foreign Remittances１ Mechanism of Foreign Remittances“Foreign remittance” refers to the transfer of funds from a Japanese bank to a beneﬁciary account in a foreign bank.
Foreign remittances are usually processed using an international interbank ﬁnancial transaction network called SWIFT(Society for Worldwide Interbank Financial Telecommunication SC, headquartered in Belgium).
SWIFT has more than 11,000 participating institutions, such as banks and securities companies, in more than 200countries and regions. Therefore, theoretically, foreign remittances can be made to countries and regions around theworld. However, there are some countries and regions to which remittances cannot be executed due to laws andregulations, such as Japan’s Foreign Exchange and Foreign Trade Act and U.S. OFAC regulations. There are alsosome countries and regions that require the submission of detailed information on remittance destinations, and ofvouchers regarding the source of remittance funds. Please contact your bank for details.
The diagram below shows the mechanism of foreign remittances. Depending on the currency to be transferred orthe remittance method, remittance from a Japanese bank directly to the destination foreign bank (ﬁnal beneﬁciarybank) may not be possible and may be executed through a different bank (intermediary bank). Intermediarybanks may be located in more than one country.

■Diagram: Mechanism of foreign remittancesInternational remittance networkApprox. 11,000 participating institutionsin more than 200 countries and regionsCountryDCountry
BIntermediarybank (2)JapanCountryCRemittancemessageRemitting bankCountryAFinal beneficiarybankReceiveIntermediarybank (1)Japan ApplicantThe bank will select the shortest remittance route,as of the bank s reception of the request.
The route may change with each request andCountry C Beneficiarymay pass through some banks.2 Information Provided to Foreign Banks and SWIFTWhen making foreign remittances, the “applicant’s name and address,” “beneﬁciary’s name and address,” “beneﬁciary’sbank name and branch,” “beneﬁciary’s account number,” among other information entered on the “Application forRemittance” and other forms, will be provided to foreign banks (ﬁnal beneﬁciary bank and intermediary bank), SWIFT,and other relevant entities.
This information is provided to foreign banks, etc. in accordance with prescribed procedures, after the banks haveensured appropriate data control based on the provisions of Japanese laws and regulations, such as the Act on theProtection of Personal Information, the Act on Prevention of Transfer of Criminal Proceeds, and the Foreign Exchangeand Foreign Trade Act, or similar laws and regulations of relevant countries, in order to prevent money launderingactivities and fund transfer to terrorists.

3 Provision of Information to Customers under the Act on the Protection of Personal InformationUnder the provisions of the amended Act on the Protection of Personal Information, which came into effect on April 1,2022, a bank as a business operator (hereinafter, the “operator”), in handling a foreign remittance requested by acustomer, must provide the principal with the information in (1) to (3) below by electromagnetic record, document, or otherappropriate methods.
(1) Name of the foreign country (name of the country in which the destination foreign bank, etc. is located)(2) Information on the personal data protection system of the foreign country which is obtained through appropriate andreasonable means(Information on the personal data protection system of the foreign country in which the destination foreign bank, etc. islocated)(3) Information on the measures for the protection of personal data taken by a third party(Information on the personal data protection measures of the destination foreign bank, etc.)However, if the operator cannot identify the name of the country in which the foreign bank, etc. is located in (1) above, it isrequired to provide the information below (for example, at the time a request for foreign remittance is received, theoperator is unable to determine whether an intermediary bank exists or its name and location, and accordingly, cannotidentify the country in which the intermediary bank is located).
(i) Information to the effect that the “name of the foreign country” cannot be identiﬁed and the reason(ii) If there is any information that can be of reference to the principal in place of the “name of the foreign country,” suchinformationIf the information in (3) above cannot be provided, notiﬁcation thereof and the reason must be provided.
With regard to (2) and (3) above, the destination foreign bank, etc. could theoretically include the nearly 10,000 banks,etc. located in more than 200 countries and regions around the world that are participating in SWIFT. Therefore, it wouldbe very difﬁcult for Japanese banks to collect and provide customers with information on the personal data protectionsystems of all foreign countries and the personal data protection measures taken by foreign banks, etc.

4 Request related to Foreign RemittancesJapanese banks put forth their best efforts to involve the fewest number of intermediary banks and intermediarycountries possible when transferring funds to the ﬁnal beneﬁciary bank. However, because of restrictions in thearrangements that banks have made with foreign banks, etc. for international settlement (correspondent arrangement), orbecause the judgment made by intermediary banks is respected, among other reasons, Japanese banks cannotdetermine the existence of an intermediary bank or its name and location at the time the remittance request is receivedand cannot identify the “name of the foreign country.”In addition, due to the vast number of countries and banks to which remittances can be executed, the ﬁnancial institutionmay be unable to provide information on the personal data protection systems of foreign countries where theintermediary bank and the ﬁnal beneﬁciary bank are located, or on the personal data protection measures taken by suchforeign banks, etc.
Please keep the above in mind, and if making a foreign remittance request, check the websites of your ﬁnancial institutionand the Japanese Bankers Association in advance for information regarding the personal data protection systems offoreign countries, etc.
Please also refer to the website of the Personal Information Protection Commission, a government administrative agency,for information on the personal data protection systems of foreign countries.
* Japanese Bankers Association website (https://www.zenginkyo.or.jp/en/useful-tools/)* Personal Information Protection Commission website (https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku[Japanese])(Prepared January 2023)